Effective Date: January 1, 2022
Last Updated on: December 13, 2023
Who We Are
When we say “Secured Investment Corp. Family of Companies,” we mean companies that are controlled by Secured Investment Corp. or are not separate legal entities, but operate as a specific division under an “assumed business name” of Secured Investment Corp. A reference to “Company”, “we” or “us” is a reference to the relevant Secured Investment Corp. Company in the Secured Investment Corp. Family of Companies that is involved in the processing activity.
The Secured Investment Corp. Family of Companies includes:
– Secured Investment Corp.
– Cogo Capital
– The Lee Arnold System of Real Estate Investing
– Lake City Servicing
– Circle of Wealth Fund III LLC
– Secured Investment High Yield Fund II, LLC
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA’s scope, like:
· personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA)
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Geolocation data. Physical location or movements.
G. Sensory data. Audio (such as call recordings) or the contents of videos you choose to upload
H. Professional or employment-related information. Current or past job history
I. Inferences drawn from other personal information. Preferences, characteristics and approximate location.
J. Sensitive Personal Information. Social Security Number, driver’s license, state identification card, or passport number; account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication.
We obtain the categories of personal information listed above from the following categories of sources:
· Directly from you. For example, from forms you complete or products and services you purchase.
· Indirectly from you. For example, from observing your actions on our Website.
Disclosure of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following purposes:
· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
· To provide, support, personalize, and develop our Website, products, and services.
· To create, maintain, customize, and secure your account with us.
· To process your requests, purchases, transactions, and payments and prevent transactional fraud.
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
· For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell personal information.
Category of Personal Information Categories of Recipients
Identifiers Partners (such as mortgage partners or real estate companies, depending on the services), advertising networks, and service providers (such as internet service providers, data analytics providers, email service providers, data storage providers, customer support providers, account management providers, operating systems and platforms).
Client Records Partners (such as mortgage partners or real estate companies, depending on the Services), advertising networks, and service providers (such as internet service providers, data analytics providers, email service providers, data storage providers, customer support providers, account management providers, operating systems and platforms).
Protected Classification Characteristics Service providers, affiliates, mortgage partners, and partner companies.
Commercial Information Partners (such as mortgage partners or real estate companies, depending on the services), advertising networks, and service providers (such as internet service providers, data analytics providers, email service providers, data storage providers, customer support providers, account management providers, operating systems and platforms).
Internet Or Other Network Activity Advertising networks and service providers (such as internet service providers, data analytics providers, data storage providers, operating systems and platforms).
Geolocation Data Partners and service providers.
Sensory Data Partners.
Professional Or Employment-Related Information Service providers and partners.
Inferences Drawn From Other Personal Information Partners, advertising networks, and service providers (such as internet service providers, data analytics providers, email service providers, data storage providers, customer support providers, account management providers, operating systems and platforms).
Sensitive Personal Information Partners (such as mortgage partners or car dealerships, depending on the Services), advertising networks, service providers (such as internet service providers, data analytics providers, email service providers, data storage providers, customer support providers, account management providers, operating systems and platforms), affiliates, and partner companies.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
· sales, identifying the personal information categories that each category of recipient purchased; and
· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
· The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
· Calling us at (800) 341-9918
· Emailing us at firstname.lastname@example.org
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
We do not knowingly sell or share personal information about consumers under the age of 16.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact the Legal Department by sending an email to email@example.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
California Financial Incentive Disclosure
California’s privacy law requires that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of personal information, which it defines as a “financial incentive.” We may offer you certain financial incentives that may result in different prices, rates, or quality levels (for example, contests and referral programs). Through these offerings, consumers provide us with some personal information (e.g., names, emails, phone numbers) when they opt-in to our programs. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in the program offering. We offer these programs, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. We invest heavily in our marketing and brands, in part, so we can provide programs to our customers. Consumer data is valuable to our business only when it is combined with a sufficient number of other consumer data and after it is enhanced by our efforts herein described. The value to our business of any individual consumer’s personal information is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings, whether and to what extent you opt out of any offerings, and whether we are able to enhance the data through our efforts herein described. Our ability to create any value from the programs is heavily based on our ability to leverage said intellectual properties. We do not calculate the value of consumer data in our accounting statements.
CCPA Rights Request Metrics
Metrics regarding the consumer rights requests we received from all individuals from January 1, 2022 to December 31, 2023 appear in the following chart:
Request Type Received Granted (in whole or in part) Denied Mean Days to Respond
Requests to Know 0 0 Unverifiable: 0.
Not by a consumer/ California resident: 0.
Called for information exempt from disclosure: 0.
Denied on other grounds: 0. Not applicable
Requests to Delete 0 0 Unverifiable: 0.
Not by a consumer: 0.
Called for information exempt from disclosure: 0.
Denied on other grounds: 0. Not applicable
If you have any questions or comments about this notice, the ways in which the Secured Investment Corp. Family of Companies collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Secured Investment Corp. Family of Companies
Attn: Legal Department
701 E Front Ave, FL 2
Coeur d’Alene, ID 83814
If you need to access this Policy in an alternative format due to having a disability, please contact firstname.lastname@example.org via email or call 800-341-9918.